The threat of new U.S. sanctions has spread anxiety among Russia’s wealthiest people that their association with President Vladimir Putin could land them on a U.S. government blacklist, members of the business elite say.

The list, to be drawn up by early next year, is part of a sanctions bill passed overwhelmingly by Congress soon after Donald Trump became president and reluctantly signed by him on Aug. 2 despite his avowed wish to improve ties with Moscow.

Although those included on the list would not automatically be sanctioned, six people who are part of the business elite or close to the Kremlin said it was a major concern because the criteria for inclusion and the consequences were unclear.

“People are on edge,” said a senior figure in a major Russian company.

“If they classify you as close to Putin, just try proving it’s not the case,” the figure said. “The Americans’ tactics are clear: they need to cause pain in all ways possible for those who support Putin.”

While most of the business elite remains loyal to Putin, the prospect of personal sanctions — which can prevent travel abroad or access to foreign bank accounts and freeze foreign assets — has prompted some to steer clear, the sources said.

A billionaire businessman who has sat on panels of business leaders with Putin and in the front row of the audience when Putin addressed conferences has adjusted his diary to avoid such occasions, a source who works closely with him said.

“He’s simply been trying lately to show up less next to Putin,” said the source, who spoke on condition neither he nor his boss be identified because of the sensitivity of the topic.

“Because it’s not clear on what basis there could be sanctions. You get the impression anyone could get hit.”

A source in the entourage of a second Russian billionaire said several oligarchs had chosen the tactic of keeping a low profile to avoid inclusion in the list.

LIST OF OLIGARCHS

One billionaire businessman in the top 100 of wealthiest Russians spoke to Reuters in person. He said he could not get any clarity from his Russian political contacts about the threat.

Asked what steps he could take to protect himself if he was included on a U.S. sanctions blacklist, he said: “There’s no way. You have to leave.” He did not say where he would go.

Unusually for one of Russia’s billionaire class — a group that presents itself as loyal to the Kremlin – he expressed frustration with senior officials, including Putin.

“The leadership (of the country) does not believe that the sanctions are going to follow the hard scenario,” said the businessman, speaking on condition of anonymity. “They live in a parallel reality. No one wants to listen to business.”

Dmitry Peskov, Kremlin spokesman, told reporters on Thursday that he was not aware of any frustration among the business elite from the new sanctions.

“We know nothing of such views. If they exist and appear, we are always open to discussion,” he said. Asked whether he believed that sanctions were aimed at setting up elites against Putin, Peskov said: “We are confident this is exactly the case.”

“The law is very bad, it’s very broad, very incoherent, its application could have all sorts of consequences,” Andrei Kostin, chief executive of VTB Russia’s second biggest bank, said this week, referring to the legislation as a whole.

The list, to be drawn up by the Treasury Department, is set to name the most significant Russian oligarchs “as determined by their closeness to the Russian regime and their net worth”.

It is meant to be sent to Congress by the end of January, weeks before Russia is due to vote in a presidential election. Though he has not declared his intentions yet, most Kremlin-watchers expect Putin to run and polls show he would easily win.

BANK CHECKS

Sanctions lawyers say the list itself has no legal force and inclusion does not mean sanctions will follow. Other provisions of the Aug 2 law present a more immediate threat by raising the level of risk for firms that do business with entities already under sanctions.

Nevertheless, Western banks have started making additional checks on people they deem to be associated with Putin, said an executive with a European bank that operates in Russia.

The checks, said the executive, were prompted by the Aug. 2 sanctions law and included establishing whether the individuals, whom he did not name, had accounts with the banks concerned. The source did not say whether they were taking any action.

Some people in Putin’s innermost circle have already been on a U.S. sanctions blacklist since 2014.

Gennady Timchenko, an oil mogul and one of Putin’s closest friends, called his inclusion in 2014 “an honour for me”. Timchenko’s wife, Elena, had her bank card rejected the same year when she tried to pay for treatment in a German clinic because her husband was under sanctions.

The planned list of oligarchs is likely to include people outside that circle, who are not unquestioning Putin loyalists yet could still be punished for their association with him.

“Everyone’s fearful for themselves, they’re afraid of personal sanctions,” said a source close to a fourth top 100 Russian billionaire. “Because, what if the whole of the Russian establishment ends up under sanctions? No one knows, so everyone is afraid.”

A senior source who is close to the government and the Kremlin said the U.S. authorities were trying to turn Putin’s allies against him, especially with the presidential election approaching.

“If all these threats become reality, in respect of other people as well, that will create powerful tension and discontent in the business elite,” said the source.